Re: RAM Security

[Maureen.Gillis@chirondiag.com]

     Could you please describe your security controls?  Do you control 
     at the point of entry into the lab or with locks and attendance?
     
     At one point, I believe the NRC stated that securing at the area 
     entrance created a restricted area so we have stayed away from 
     locking the entrances as much as possible.
     
     So, to date we have secured a limited number of areas (e.g. the 
     Tracer Manufacturing Area and the Storage-for-Decay Area) and 
     locked or attended all other sources using the action levels of 
     App. C.  (This was found acceptable in a 5/95 inspection with the 
     NRC.)
     
     Last week's guidance from the NRC looks like the exception for 
     quantities below App. C levels is on its way out.
     
     I would appreciate the comments of others on the strict 
     implementation of security controls.
     
     Thank you.
     
     Maureen Gillis
     Chiron Diagnostics Corporation
     E. Walpole, MA 
     maureen.gillis@chirondiag.com
     Tel.# 508-660-4207
     Fax # 508-660-4591
     

______________________________ Reply Separator _________________________________
Subject: RAM Security
Author:  "Kenneth W. Price" <75301.361@compuserve.com> at cclink
Date:    5/19/98 1:26 PM


We have a security enforcement program in place which does not consider the
quantity in the research labs.   I can envision an "on" again "off" again
secruity program and investigators stating that they had less than App. C
qunatities in their areas when we cite them for security.  In an active
research environment it seems impossible to do anything other than require
that "all radioactive materials" be secured from unauthorized access.  Our
program has worked well and it is very unusual to find a research lab
unsecured.  In the beginning, we had near 15% of the labs being cited for
security violations.  It is now below 1% and very often 0%.  Please, no
comments about natural radioactivity in the glassware or K-40 in each lab
worker's body.  We all know what the intent of the law is, and in the
current regulatory environment, we have no choice.  

Kenneth Price, MPH, CHP
University of Connecticut Health Center
Farmington, Ct
75301.361@compuserve.com